This Note has four objectives. First, this Note will summarize the facts of Coffey. Second, this Note will review the history of parent-child immunity and the role of the family purpose doctrine in cases involving parent-child immunity in automobile cases. Third, this Note will analyze the Coffey case, the North Carolina Legislature's abolishment of parent-child immunity in motor vehicle cases, and possible alternatives to the parent-child immunity doctrine in cases other than those involving motor vehicles. Fourth, this Note will suggest that the North Carolina courts are not powerless to abrogate parent-child immunity. The courts should take the initiative to modernize the judicially created parent- child immunity doctrine as it applies to tort actions between parents and their children.

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